News & Analysis as of

Federal Sentencing Guidelines Penalties

Society of Corporate Compliance and Ethics...

How a code of conduct reflects culture and meets DOJ requirements

Every compliance program begins with a code of conduct. The code of conduct expresses a company’s fundamental values and its commitment to living by them. Although a code of conduct is usually a very high-level document, it...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action - Part 4: The Double Whammy in Penalties

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

A&O Shearman

Korean Engineering Company Fined $75 Million Over Alleged Foreign Bribery Scheme In Brazil

A&O Shearman on

On November 22, 2019, the U.S. Department of Justice (“DOJ”) announced that it had entered into a three-year deferred prosecution agreement (“DPA”) with a Korean engineering company (“SHI”) to settle allegations of Foreign...more

The Volkov Law Group

Samsung Agrees to Pay $75 Million to Resolve FCPA Violations (Part I of II)

The Volkov Law Group on

Samsung Heavy Industries agreed with the Justice Department to pay $75 million to settle FCPA charges. Under a three-year deferred prosecution agreement (DPA), Samsung agreed to filing of a criminal information in the Eastern...more

Thomas Fox - Compliance Evangelist

JPMorgan Sons and Daughters FCPA Enforcement Action, Part III-St. Mark’s Revealed

This week I am exploring the JP Morgan Chase (JPM) and its subsidiary, JPMorgan Securities (Asia Pacific) Limited (JPM-APAC), (collectively ‘the company’) Foreign Corrupt Practices Act (FCPA) enforcement action which...more

Thomas Fox - Compliance Evangelist

JPMorgan Sons and Daughters FCPA Enforcement Action: Part I – Venice and Fog

JP Morgan Chase (JPM) and its subsidiary, JPMorgan Securities (Asia Pacific) Limited (JPM-APAC) resolved its Foreign Corrupt Practices Act (FCPA) matter last week, obtaining a Non-Prosecution Agreement (NPA) from the...more

K&L Gates LLP

The Burden of Corporate Probation May Follow an Antitrust Conviction

K&L Gates LLP on

The Antitrust Division of the Department of Justice (the “Division”) has announced a major policy shift. When a company has been convicted for a criminal antitrust offense, the Division may seek to impose the significant...more

Thomas Fox - Compliance Evangelist

What Is ‘Acceptance Of Responsibility’ Under The US Sentencing Guidelines?

One of the things that I am often asked is how are fines and penalties calculated for Foreign Corrupt Practices Act (FCPA) violations? ...more

Morrison & Foerster LLP

Insider Trading Annual Review - 2012

In This Issue: Overview Of Insider Trading Law; 2012 Enforcement activity; Galleon Update; Expert Network Cases; What Does Cooperation Buy You?; Global Trading, Global Enforcement; Legislative Reform; 10b5-1 Plans: Not...more

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